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A User’s Guide to Billing & Coding for Telehealth During COVID-19


Billing and coding has never been a simple process, but adding COVID-19 and rapidly changing CMS guidelines related to telehealth and you have the recipe for confusion – particularly for many busy practices and providers who are managing newly implemented telehealth technology, and the staffing and safety concerns that come with balancing daily operations and a global pandemic.

Telehealth Options

The choices for telehealth have expanded – with more options eligible for reimbursement during COVID-19. Here is a quick summary of the avenues available for connecting with patients virtually.

  • Virtual Check-Up: New guidelines allow for telephone/real-time or “2-way audio interactions that are enhanced with video or other data transmission” for new or established patients. These visits are ideal for chronic patients who need assessment before determining whether an in-person visit is required. Note: This service must be provided by a clinician who can bill E/M services (i.e., not a nurse or medical assistant, etc.) All geographic restrictions for patient location have been lifted. Finally, if it’s determined that an office visit is necessary, the in-person visit should be bundled with the virtual check-up.
  • Digital E/M: This refers to a patient-initiated evaluation for an established patient that takes more than 5 minutes of a clinician’s time, and it can only be used once per 7-day period (more specific rules apply if the patient calls back within the 7-day period, check CPT guidelines for details on how to count time and count the 7 days, etc.). According to the American College of Physicians, this visit can be done ‘synchronously and asynchronously and audio/video phone can be used, but not a traditional telephone.’
  • Remote Monitoring: Available for new or established patients, this type of telehealth allows for the ‘asynchronous transmission of healthcare information’ from the patient – such as temperature, blood pressure, oxygen saturation, glucose monitoring, etc. During the COVID-19 public health emergency (PHE), the 16-day minimum requirement has been lifted and this service can be used for any period of time, 2 days or longer. Follow-up related to remote monitoring can be by phone, secure text, email, patient portal, or audio/video.
  • Phone Calls: While technically not considered telehealth, audio-only calls (for new or established patients) used as a replacement for care that would normally be billed as in-person or telehealth during the COVID-19 PHE are eligible for reimbursement at the rate of E/M codes 99212-99214. Retroactive from March 1, 2020, this change went into effect on April 30, 2020. Note: Be sure to document verbal consent and why neither audio/video or an in-person visit could be completed.

Regulations During COVID-19

Since March 2020, the Centers for Medicare & Medicaid Services has been relaxing its strict regulations related to reimbursement for telehealth services to allow for widespread utilization and adoption – allowing both patients and healthcare providers to limit interactions and reduce the spread while getting the care they need. Among the major (temporary) changes made are:

  • Patients can receive telehealth services at home using non-HIPAA compliant technology such as Apple FaceTime, Skype, Facebook Messenger Chat, etc.
  • In many cases, providers can be reimbursed at the same rate as they would for in-person care. During the COVID-19 PHE, use a -95 append modifier when coding for services provided using real-time audio and video (NOT applicable for virtual visits, digital evaluations, or telephone calls). The use of this modifier will ensure that you can be reimbursed the same as if the encounter was completed in-person.
  • Cost-sharing for all telehealth services (i.e., copays and deductibles) can be reduced or waived.
  • Many regulations related to prior authorization have been relaxed or paused.

Depending on the duration of the COVID-19 PHE, the rules around telehealth may continue to evolve. While there are many great resources out there to provide updates on billing and coding for telehealth, we recommend looking to credible sources such as the Centers for Medicare & Medicaid Services; the American College of Physicians; any specialty-specific professional organization (i.e., American Academy of Pediatrics, American College of Obstetricians & Gynecologists, etc.); individual payer partners; and if applicable, your outsourced billing and coding partners. Using these sources for credible information will ensure you are working with the most accurate and up-to-date information that relates to virtually any telehealth or related service.


GeBBS Healthcare Solutions offers a full spectrum of outsourced medical billing, collections, coding, and telehealth expertise. With the recent challenges of COVID-19, telehealth has gone from a “somewhere in the future” patient care technology to a now technology and immediate adoption has never been more critical – GeBBS diligently works side-by-side with our large client base and industry experts alike to navigate the associated complexities of telehealth. GeBBS’ leadership and SMEs remain at the forefront of change, by continuously monitoring updates and releases and partnering with leading industry experts to transfer and share our knowledge that ensures our clients remain current and compliant in the everchanging world of healthcare. To learn more, visit gebbs.com

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